December 23, 2025
In This Issue:
- FinCEN Publishes Guidance to Help Prepare for Upcoming Residential Real Estate Reporting Requirements Effective March 1, 2026
- TDI Orders Reduction of Title Insurance Basic Premium Rate Beginning March 1, 2026
- TDI Holiday Hours
FinCEN Publishes Guidance to Help Prepare for Upcoming Residential Real Estate Reporting Requirements Effective March 1, 2026
TLTA | Dec. 23, 2025
FinCEN published new guidance on the upcoming reporting requirements for certain all-cash residential real estate transactions:
Quick reference guides containing general information about reporting requirements
Instructions on how to complete the report
Technical guidance for batch XML filers
Testing environment for reporting, where filers can test their submission capabilities
TLTA Offers New Compliance Clinic to Help Title Industry Prepare for These New Reporting Requirements, Which Could Go Into Effect in March
FinCEN Real Estate Reporting Rule: Final Prep Before March 1 Effective Date
Wednesday, February 11, 2026
10:00 a.m. – 11:30 a.m.
CE: 1.5 hours Escrow/MCLE
ICYMI: Federal Magistrate Recommends District Court Rule in Favor of FinCEN in Suit Challenging Implementation of FinCEN’s New All-Cash Residential Real Estate Reporting Rule That Could Go Into Effect Early Next Year
In a document filed last week, a U.S. magistrate recommended that the United States District Court for the Middle District of Florida grant FinCEN’s cross-motion for summary judgment in
Fidelity National Financial, Inc., et al. v. U.S. Department of the Treasury, et al., Case No. 3:25-cv-554 (M.D. Fla.).
In the suit, Fidelity National Financial and Fidelity National Title Insurance Company challenged a new FinCEN rule requiring reporting of certain all-cash residential real estate transactions. The magistrate recommended that the court rule in favor of the government, uphold the rule, and deny Fidelity’s challenge in its entirety.
The new FinCEN rule challenged in the suit would expand and replace FinCEN’s prior temporary, geographically limited Geographic Targeting Orders (GTOs). The magistrate’s recommendation, if adopted, could clear the way for nationwide enforcement of the rule beginning in 2026.
Review the Magistrate’s Recommendation »
TDI Orders Reduction of Title Insurance Basic Premium Rate Beginning March 1, 2026
TLTA | Dec. 23, 2025
At a hearing Dec. 19, TDI announced adoption of a -6.2% reduction of the title insurance basic premium rate that will be implemented March 1.
Read TDI's order »
You can learn more about the rate reduction process that began two-and-a-half-years ago:
2023-2025 Basic Premium Rate Review & Hearing »
2025 Basic Premium Rate Hearing »
If you have questions, please contact
Aaron Day, TLTA Vice President of Government Relations and Counsel.
TDI Holiday Hours
TLTA | Dec. 23, 2025
The Texas Department of Insurance will have limited hours of availability during the upcoming holidays:
Dec. 23: Close at noon
Dec 24-26: Closed
Dec. 31: Close at noon
Jan. 1: Closed